Keefe v. Adams et al.

840 F.3d 523 (8th Cir. 2016)

In December 2012, former nursing student Craig Keefe was expelled from Central Lakes College’s Associate Degree Nursing Program for Facebook posts he made, including one in which he described a classmate as a “stupid bitch.” The Facebook posts were made on Keefe’s personal account, but were reported to an instructor by two students in November 2012 after they were made uncomfortable by some of the language in them. After questioning Keefe about the comments, the college determined that the posts were contradictory to the student handbook’s policy on professional behavior. Keefe’s appeal to expulsion was denied in January 2013.

In February 2013, Keefe sued Beth Adams, the dean of the college, and other college officials who he said were responsible for the decision to expel him. Keefe alleged First Amendment and Due Process rights violations.

In August 2014, the U.S. District Court of Minnesota dismissed Keefe’s case, ruling that the college was entitled to discipline Keefe for the Facebook posts because they were enforcing academic standards of professionalism. The Eighth Circuit Court of Appeals affirmed, ruling that Keefe was dismissed for unprofessional behavior and that “substantial disruption” and “true threat” standards of analysis were “not implicated when assessing academic program rules.”